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In July 2005, I delivered a review of advancements since my 2003 keynote speech to Eusprig, focusing on spreadsheet usage concerns in the financial industry shared by the Financial Services Authority (FSA). Progress has been observed in areas such as IT strategy acknowledgment, user training, and increased awareness in audit reports. However, challenges persist, including the need for better practices and the burden of accreditation. This update highlights both the strides made and the ongoing difficulties in addressing the "M" problem and ensuring effective data management.
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Regulatory Update Dean Buckner UK Financial Services Authority July 2005
Summary • In 2003 I made keynote speech to Eusprig • Highlighting areas where FSA concerned about spreadsheet use in financial industry • Today I shall review progress made in these areas • As always, there is good news and bad
Issues in 2003 • Change of mindset (senior mgt, IT) • User training • No “good practice” • Accreditation • Audit awareness • Data standards • The “M” problem
Management mindset • We would like firms to have an IT strategy on spreadsheets • More than just “aim to replace them”! • Some good news • IT directors increasingly admit need for strategy • One bank now explicitly recognise this (Case study I) • Sarbanes Oxley implications • Bad news • Hard to see “big picture”
User training • Most problems the result of poor use of EUC solutions • Falls under “stupid practice” • (Case study II) • Good training the obvious solution • But no IT budget! • This would mean explicit acceptance of supposedly “tactical” solutions • Connects with IT strategy issue
Good practice • Good news • EUC policy now becoming a standard (in banks at least) • Bad news • Policy tends to be very high level • Eusprig has no view on good practice • FSA’s position is that this is industry issue
Accreditation • No good news • Accreditation seen as burdensome and risky • And difficult (implies generally accepted view on good practice, for a start)
Audit • Very good news • We are seeing more mention of spreadsheets in audit reports • Doesn’t mean spreadsheet use increasing! • Does mean that auditors now recognise spreadsheets exist! • And EUC part of audit plan • Thanks to Eusprig • Impact of Sarbanes Oxley?
Data • Data processing is the biggest problem • Mostly done on spreadsheets, via ad-hoc and “hacky” downloads • Increasing use of ACCESS in bad ways • No “vested interest” in good data (even in Eusprig community) • Basel has helped a bit • Concept of “data ownership” • Sarbanes-Oxley may help
“M” problem • Some good news • Dialogue opened up with banks and FSA • Apparent willingness • But obvious difficulties • Which problems are “M” specific? • Or is it just bad use of a good tool? • Some issues: code fragmentation, poor help, poor data transfer (try moving UK date formats from ACCESS to EXCEL), 256 column problem, ACCESS security &c &c
Sarbanes Oxley • Requires firms to demonstrate that controls around financial reporting are adequate • Requires auditor to • Assess effectiveness of management assessment of internal controls • Assess effectiveness of internal controls • Requirement to demonstrate EUC controls is particularly onerous (because they are usually not documented)